A Year of Structural Change
2026 wasn’t a year of incremental healthcare policy adjustments. It was a year of structural shifts that will define how safety-net hospitals, FQHCs, and specialty practices operate for years to come.
From the 340B Drug Acquisition Cost Survey launch to permanent telehealth rules to the Rural Health Transformation Program, the policy landscape moved faster than many organizations were prepared to handle. This review focuses on the changes that carry the most operational significance heading into 2027.
340B: The Data Is Now Flowing to CMS
The most consequential 340B development of 2026 was the launch of the Drug Acquisition Cost Survey in July. For the first time, CMS is collecting systematic data on what 340B hospitals actually pay for drugs.
The U.S. District Court for the District of Maine’s AHA v. Kennedy ruling vacated the rebate model pilot, preserving the traditional 340B pricing structure. But that victory may be temporary. With acquisition cost data in hand, CMS has the legal foundation to propose payment adjustments in the CY 2027 OPPS final rule.
Manufacturer restrictions continued to expand, with 39 companies now imposing conditions on 340B contract pharmacy access. State legislatures pushed back with multiple states enacting 340B protection laws, with at least eight states having enacted substantive legislation. The federal-state-manufacturer tug-of-war will intensify in 2027.
Action for 2027: complete your first full year of survey submissions with clean data. Model the financial impact of potential reimbursement reductions. Strengthen your community benefit documentation.
Telehealth: Permanent but Not Settled
CMS made key telehealth flexibilities permanent in 2026, ending years of temporary extensions. Providers can now deliver most telehealth services to patients at home without geographic restrictions.
But the details still matter. In-person visit requirements for mental health telehealth kicked in, audio-only coverage remains limited to specified services, and the originating site facility fee was eliminated for home-based visits. These nuances affect revenue and operational design.
The bigger question heading into 2027 is whether the 2027 extension cliff for certain telehealth provisions will result in permanent authorization or another round of temporary patches. Congress has shown willingness to extend telehealth flexibilities but hasn’t committed to making all of them permanent.
Action for 2027: audit your telehealth billing for compliance with permanent rules. Build quality measurement infrastructure to demonstrate outcomes. Engage in the legislative process to support permanent telehealth authorization.
Management Services: Growing Demand, Growing Scrutiny
The management services model gained significant traction in 2026 as safety-net providers sought operational support without giving up ownership. MSO partnerships expanded across FQHCs, CAHs, and specialty practices.
At the same time, regulatory scrutiny of management arrangements intensified. The DOJ pursued several enforcement actions involving MSA structures that failed to meet Stark Law and Anti-Kickback Statute requirements. OIG issued a Special Fraud Alert on management fee arrangements that tied compensation to referral volume.
The message is clear: the MSO model works, but only when the legal structure is bulletproof. Organizations that cut corners on fair market value documentation, compliance provisions, or governance boundaries will face enforcement attention.
Action for 2027: review your existing MSAs against current regulatory guidance. Obtain updated fair market value opinions for any arrangements older than two years. Ensure your governance documentation clearly demonstrates clinical independence.
What to Prepare For in 2027
Several policy developments will demand attention in 2027.
The CY 2027 OPPS final rule, expected in November 2026, will reveal whether CMS plans to use Drug Acquisition Cost Survey data to adjust 340B drug reimbursement. This is the single highest-stakes policy event for 340B hospitals.
Congressional action on Medicaid DSH allotments will determine whether the scheduled $8 billion in cuts proceed, are delayed, or are restructured. DSH hospitals should have advocacy strategies ready for either outcome.
The second cohort of the Rural Health Transformation Program will open for applications, offering Critical Access Hospitals a new path to operational and financial sustainability.
And the ongoing evolution of AI in healthcare operations will continue to create opportunities and risks across revenue cycle management, clinical documentation, and compliance monitoring.
The organizations that thrive in 2027 won’t be the ones that react to these changes. They’ll be the ones that anticipated them, planned for them, and built the operational infrastructure to adapt.
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━
Nexwell Health Partners provides management services, telehealth solutions, and compliance support for safety-net hospitals, FQHCs, and specialty practices. Contact us to schedule a consultation.
Sources